Data protection

The Management / Governing Body of BOOKISH VENTURES, S.L (hereinafter, the data controller), assumes the highest responsibility and commitment to the establishment, implementation, and maintenance of this Data Protection Policy, ensuring the continuous improvement of the data controller with the aim of achieving excellence in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119/1, 04-05-2016), and Spanish legislation on personal data protection (Organic Law, specific sectoral legislation, and its implementing regulations).

The Data Protection Policy of BOOKISH VENTURES, S.L is based on the principle of proactive responsibility, whereby the data controller is responsible for compliance with the legal and jurisprudential framework governing this Policy and is able to demonstrate it to the competent supervisory authorities.

Principles

In this sense, the data controller will be governed by the following principles that should guide and frame all staff in the processing of personal data:

• Data protection by design: The data controller will apply, both when determining the means of processing and at the time of processing itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively apply the principles of data protection, such as data minimization, and to integrate the necessary safeguards into the processing.
• Data protection by default: The data controller will apply appropriate technical and organizational measures to ensure that, by default, only personal data necessary for each specific purpose of the processing are subject to processing.
• Data protection throughout the information lifecycle: Measures to ensure the protection of personal data will apply throughout the entire lifecycle of the information.
• Lawfulness, fairness, and transparency: Personal data will be processed lawfully, fairly, and transparently in relation to the data subject.
• Purpose limitation: Personal data will be collected for specified, explicit, and legitimate purposes and will not be further processed in a manner incompatible with those purposes.
• Data minimization: Personal data will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
• Accuracy: Personal data will be accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that inaccurate personal data, considering the purposes for which they are processed, are erased or rectified without delay.
• Storage limitation: Personal data will be kept in a form that allows the identification of data subjects for no longer than necessary for the purposes for which the personal data are processed.
• Integrity and confidentiality: Personal data will be processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
• Information and training: One of the keys to ensuring the protection of personal data is the training and information provided to staff involved in processing them. During the information lifecycle, all staff with access to the data will be adequately trained and informed about their obligations regarding compliance with data protection regulations.

The Data Protection Policy of BOOKISH VENTURES, S.L is communicated to all staff of the data controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all staff of the data controller, who must know and assume it, considering it their own, with each member being responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and providing improvement opportunities they deem appropriate to achieve excellence in compliance.

This Policy will be reviewed by the Management / Governing Body of BOOKISH VENTURES, S.L as often as deemed necessary to adapt it, at all times, to the provisions in force regarding personal data protection.